Alphatec Holdings, Inc.
5818 El Camino Real
Carlsbad, California 92008
April 9, 2010
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attention: | Gabriel Eckstein, Esq. | |
| Mail Stop 3030 |
| RE: | Alphatec Holdings, Inc. |
Registration Statement on Form S-3 (File No. 333-164891)
Acceleration Request
Dear Mr. Eckstein:
Pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, Alphatec Holdings, Inc. (the “Company”) hereby respectfully requests that the Securities and Exchange Commission (the “Commission”) accelerate the effectiveness of the above-captioned Registration Statement on Form S-3 to Friday, April 9, 2010, at 5:00 p.m. Eastern Time, or as soon as practicable thereafter.
In connection with the foregoing request, the Company acknowledges that:
| • | should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| • | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
The cooperation of the staff in meeting the timetable described above is very much appreciated.
Any questions regarding this request should be addressed to Michael L. Fantozzi, Esq., at Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., One Financial Center, Boston, Massachusetts 02111, telephone (617) 542-6000.
| Very truly yours, | ||
| ALPHATEC HOLDINGS, INC. | ||
/s/ Ebun S. Garner | ||
| By: | Ebun S. Garner, Esq. | |
| Its: | General Counsel and Vice President, Compliance | |
| cc: | Russell Mancuso, Esq.,Securities and Exchange Commission |
Michael L. Fantozzi, Esq.,Mintz Levin
